Privacy requests, retention and legal holds

Privacy covers what people can ask about their data, how long records are kept, and legal holds that stop anything from being removed. Customer consents (version 3) are kept on each customer.

Requests from people

Compliance > Privacy requests > Log a request records a request: to see their data, correct it, erase it, take it elsewhere, stop a use of it, or restrict it. It is linked to the customer when known, and due 30 days after it was received. The compliance team is told when one arrives, five days before it is due, and when it is late.

1. Identity checked: confirm the person is who they say they are. Nothing can be answered before.
2. Export their data gathers everything held on the customer (details, policies, claims, invoices, payments, consents, contacts, messages, emails, identity documents, owners) as one JSON file, attached to the request.
3. Answer closes the request with what was done. For an erasure, answering erases the customer (below), or it can be refused with the reason.

Erasure

A customer can be erased only when nothing requires the data to be kept: no legal hold, no policy in force, no open claim, nothing owed, and no open or reported suspicious activity. The reason is shown when it cannot be done.

Erasure replaces the name with Erased customer and a number and removes contact details, identity numbers, date of birth and notes; messages, emails, contact history, portal access and bank details are deleted. Policies, invoices and payments stay without the personal details, because the accounts must be kept.

Retention rules

Compliance > Retention rules sets how long each kind of record is kept: customers with no policy or claim, leads, quotes not taken up, closed claims (their descriptions are cleared), email, SMS and contact logs, inbound email, the audit trail and the access log. Each rule has a number of years and whether records are anonymised or deleted. Active rules run every Sunday. Run now applies one rule immediately; the list shows when it last ran and how many records it removed.

Legal holds

Compliance > Legal holds > Place a hold keeps a customer or a claim, with everything linked to it, out of erasure and retention, for a court case, an investigation or a regulator's request. A hold can have an end date or be released by hand. In force lists the holds that apply today.